Saltire Capital Partners Pty Limited ACN 70 633 357 721 (“Saltire Capital Partners” or “we” or “us”) believes that the privacy of its information is critical. Information on our policies and practices relating to privacy are outlined below.
Saltire Capital Partners is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act) and we take these obligations seriously.
Where appropriate Saltire Capital Partners will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act.
What personal information is collected and why
What we collect
We collect information about individuals:
- who use our websites, social media and other online services (Online Services);
- who register, login or subscribe to join/receive our thought leadership, webinars, seminars, conferences and industry roundtables; and
- to whom we provide professional services.
The types of personal information we collect includes name, contact details, gender, identification information, payment details, registration and activity details relating to our Online Services (such as the date and time you accessed each page on our website; the fully qualified domain name from which you access our websites, or alternatively, your IP address; the URL of any webpage from which you accessed our websites; cookies which track your visits to our websites and the web browsers that you are using and the pages you accessed), transaction details, interests and preferences, device details (including device identifiers, usage and location data), information submitted in forms, enquiry/complaint details and records of communications and interactions.
We generally do not collect “sensitive information”. If we do, we will seek consent to collect it if required by law to do so with the express consent of the individual and in accordance with the Privacy Act.
How we collect
We collect personal information from you and from other sources including publicly available information, your representatives, information service providers, service providers who collect personal information on our behalf and the parties with which we exchange information as described here.
Why we collect
We collect, hold, use and disclose your personal information for purposes including to provide, administer, improve and personalise our services, process payments, identify you, communicate with you (including direct marketing), investigate and deal with unlawful activity and misconduct, respond to lawful information requests from courts, government agencies and lawyers, protect our lawful interests and deal with your enquiries and concerns.
If a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest in Saltire Capital Partners we may disclose personal information to that third party or its advisors.
Personal information we collect may also be used for purposes related to Saltire Capital Partner’s research (including market research), planning, service development, testing, customer relationship management and records management.
To help us understand and serve you better, we may combine personal information we hold about you with personal and non-personal information from different sources. For example, we may obtain demographic data from an information service provider to tell us about the interests of Companies in your industry and use it to help us predict which services might appeal to you. These sorts of activities may be conducted in connection with our Online Services as described further below.
Users of our Online Services are not required to provide us with any personal information. However, we may not be able to provide the information or service a user requests – including access to, and use of, thought leadership – if the personal information which is indicated as mandatory is not provided.
We may also collect aggregated information which tells us about users of our Online Services but not the identity of those users, unless they register to access thought leadership (in which case, the identity of a user may become apparent). For example, we may collect information about the date, time and duration of visits and which pages or parts of those Online Services are most commonly accessed. We may also collect internet address domain names, the previous websites visited and the types of browser visitors are using. This information is used by us for internal research, statistical and website development purposes. It may also be used by us to provide users with services and other content.
Our Online Services may use “cookies”. A cookie is a small message in a text file, and the message is then sent back to the server each time the browser requests a page from the server.
Our Online Services may, from time to time, contain links to the websites and online services of other organisations which may be of interest to you. Those other organisations are responsible for their own privacy practices and you should check those websites and online services for their respective privacy policies.
Exchange of Personal Information with Third Parties
We may exchange personal information with our service providers and contractors such as organisations who provide archival, auditing, professional advisory (including legal, accounting and business consulting), debt collection, banking, marketing, advertising, communication, mail house, delivery, recruitment, call centre, contact management; technology, research and analytics services.
We may exchange personal information with regulatory authorities where required or authorised by law or to assist in the prevention, detection and management of unlawful conduct.
Some of the parties with which we exchange personal information are located outside Australia in countries like Singapore and the United States of America. While these third parties will often be subject to privacy and confidentiality obligations, you acknowledge that:
they may not always comply with those obligations or those obligations may differ from Australian privacy laws;
- we will not be accountable for the third party under the Privacy Act;
- you may not be able to seek redress under the Privacy Act; and
- the third party may be subject to foreign laws which might compel further disclosures of personal information (e.g. to government authorities).
Storage of Personal Information
We hold personal information in physical files, computer systems or in a database held by us and by service providers on our behalf. We regard the security of personal information as a priority and use a number of physical and electronic to protect it. Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. So while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us and individuals do so at their own risk.
A username and password may be essential for you to use some of our Online Services or parts of them. For your own protection, we require you to keep these details confidential and to change your password regularly (if applicable).
Personal information is only retained for as long as it is necessary for the identified purposes, to the extent necessary for purposes reasonably related to those identified purposes (for example, resolving disputes) or as required by law.
Access, updating and further information
In most circumstances, you have a right to access any personal information which we collect and hold about you and to have it corrected if it is wrong. We may deny your request for access or correction in some circumstances, but if we do this, we will tell you why. Where we decide not to make a requested correction and you disagree, you may ask us to make a note of your requested correction with the information.
If you have registered your details for our Online Services you may be able to access and update personal information on your profile, subject to any authentication and authorisation considerations, which exist to protect your security.
If you request, we will take reasonable steps to notify any third party to whom we have provided your personal information of the changes that have been made.
Please contact our Privacy Officer using the details set out below if you wish to:
make a request for access to or correction of any personal information that we may hold about you; or
make a complaint about the way in which we have handled your personal information.
We will try to address any privacy issues you may have. Any information that we provide in response may be limited to the extent permitted by any applicable law. See the “Complaints” page under “Contact Saltire Capital Partners” on the saltirecapitalpartners.com.au website for further information about our complaint handling procedures.
The Privacy Officer can be contacted using any of the following means:
Privacy Officer C/- Company Secretary
Saltire Capital Partners
PO Box Q994, Queen Victoria Building
Sydney NSW 1230
If you still feel your issue hasn’t been resolved to your satisfaction, you can escalate your privacy concern by contacting the Office of the Australian Information Commissioner.